https://www.taxtmi.com/caselaws?id=429204 Where an Indian associated enterprise had been remunerated at arm's length and no transfer pricing adjustment survived, no further profit attribution to an alleged dependent agent permanent establishment was warranted. Receipts for online auction services and platform access were not royalty because there was no right to use equipment or transfer of control over equipment. The same receipts were not fee for technical services because the services were standardised and did not make available technical knowledge, skill, or experience to the recipient. The amended agreement could not be ignored to assess notional income, as it was neither shown to be sham nor displaced by the Revenue's position in other years. en-us Mon, 17 Oct 2022 00:00:00 +0530 Thu, 20 Oct 2022 08:18:15 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=429204 Where an Indian associated enterprise had been remunerated at arm's length and no transfer pricing adjustment survived, no further profit attribution to an alleged dependent agent permanent establishment was warranted. Receipts for online auction services and platform access were not royalty because there was no right to use equipment or transfer of control over equipment. The same receipts were not fee for technical services because the services were standardised and did not make available technical knowledge, skill, or experience to the recipient. The amended agreement could not be ignored to assess notional income, as it was neither shown to be sham nor displaced by the Revenue's position in other years. Case-Laws Income Tax Mon, 17 Oct 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=429204